ML19350A052
| ML19350A052 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/06/1980 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0578, RTR-NUREG-578 80-285, NUDOCS 8012010096 | |
| Download: ML19350A052 (4) | |
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e EOSTON EDISON COMPANY Osmanat Orriens sOO navterou stacar SO ETON. M ASSACM UStrTo 0219 9 A. V. M O RISI MANAGER NUCLEAR OPERATIONS SUPPORT DEPARTMENT Nov mber 6, 1980
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Mr. Thomas A. Ippolito, Chief Operating Reactors Branch #2 Division of Licensing
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Office of Nuclear Reactor Regul'ation e,["'D_3 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 License No. OPR-35 Docket No. # -293 so-NUREG-0578 Imolementation Ref. A.) NRC letter dated July 2,1980, "Model Technical Specifications for Cat.
"A" Impl ementation" 3.) NRC letter dated April 3,1980, " Evaluation of PNPS Response to Short Tenn Lessons Learned" C.) NRC [[letter::05000293/LER-1980-034-03, /03L-0:on 800701,HPCI Turbine Discharge Line Snubber S23-3-31 Found Severed.On 800716,snubber 23-3-36 Found Severed.Cause Not Stated.Analysis Initiated.Temporary Snubber Installed|letter dated July 31, 1980]], " Interim Criteria for Shif t Staffing" D.) NRC letter dated Sept.'5, 1980 " Preliminary Clarification of TMI Action Plan Requirements" E.) NRC letter dated May 12, 1980, " Amendment No.
42 to 0.L. #DPR-35" F.) Federal Register /Vol. 45, No.132/ Tuesday, July 8, 1980/pages 45916-45917/ Proposed Rules
Dear Sir:
Your Reference A.) letter requested Technical Specification changes relative to items 2.1.1, 2.1.3.a. 2.1.3.b, 2.1.4, 2.1.6.a, 2.1.8.c, and 2.2.1.b of the TMI Lessons Learned NUREG 0578, and included Model Technical Specifications to aid Utilities in the development of their own plant specific versions.
Boston Edison Company has reviewed these model Technical Specifications for applicability at Pilgrim Nuclear Power Station and has determined that no Technical Specification changes are necessary for the reasons as indicated below:
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/!O 80120100fle g
CD3 TON E38 ON COMPANY Mr. Thomas A. Ippolito, Chief November 6,1980 Page 2 Item 2.1.1 " Emergency Power Supply Requirement" No modifications were necessary at Pilgrim Station to comply with the requirements of this item as existing plant designs, technical specifications and station pro-cedures were all determined adequate to insure that emergency power is available for power-operated relief valves, air compressors, and reactor water level in-strumentation via Reference B.
Item 2.1.3.b " Instrumentation for Inadequate Core Coolino" Per Refernece D), clarti1 cation has been provided relative to new implementation and design detail submittal dates. As such, a description of any planned mod-ifications for an instrumentation system for monitoring of inadequate core cooling will be provided by the January 1,1981 date. Therefore, Technical Specification changes are not considered appropriate until af ter the January 1,1982 implementa-tion date.
Item 2.1.4 " Diverse Containment Isolation" Technical Specification changes to incorporate changes made to comply with this requirenent have already been issued by the Commission via Reference E.).
Item 2.1.3.a " Direct Indication of Valve Position" This item requires that the reactor coolant system relief and eafety valves be provided with a positive indication in the control room, derived from a reliable valve position detection device or a reliable indication of flow in the discharge pipe. To accomplish this, all spring safety and safety / relief valves at Pilgrim Station were equipped with acoustic monitoring devices which indicate flow in the discharge line or tail pipe assembly. Additional back-up indication is pro-vided by temperature monitoring with thermocouples installed on each discharge or tail pipe.
However, it is our position that placing this instrumentation into the Technical Specifications is inappropriate, as operability of the S/RV position instrumentation is not related to safe shutdown capabilities of the plant and in addition, the loss of this equipment would not reduce the operator's awareness of S/RV operation, since the following signals are also available to the operator:
Decrease in Reactor Pressure Decrease in Megawatt Output Decrease in Steam Flow to Turbine Change in Turbine Control Valve Position Increase in Torus Temperature Increase in AP between Drywell and Torus Increased Temperature on Tailpipe Thermocouples I
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bC, TON EDCON COMPANY Mr. Thomas A. Ippolito, Chief November 6,1980 Page 3 Item 2.2.1.b " Shift Technical Advisor As required, we have made provisions for an On-Shif t Technical Advisor (STA) to serve the two functions of accident assessment and operating experience assess-ment. However, since the title of this individual.(STA) is considered temporary, incorporating this position into Technical Specifications would serve as an administrative hindrence during the current negotiations of the shift manning concerns of Reference C.).
Therefore, changes to the Technical Specifications in the above regard will be addressed via Reference C.) correspondence.
Itsns 2.1.6.a & 2.1.8.c Item 2.1.6.a "Systens Intecrity" "The NRC objective is to eliminate or prevent the release of significant
---amounts or radioactivity to the environment via leakage from engineered safety systems and auxiliary systems....
Based on our discussions at the NRR/01E site visit, we find that the licensee has tested and measured leak tightness of systems; developed leak reduction measures and implemented a preventative maintenance program.
We conclude that the licensee has satisfied the requirements of this Category "A" iten."
Item 2.1.8.c " Improved Iodine Instrunentation" "The NRC Category "A" requirenents are that each licensee shall provide equipment and associated training and procedures for accurately determining the airborne iodine concentration in areas within the facility where personnel may be preser,t following an accident.
- The licensee stated at the site visit....
Based on the above, we conclude that the licensee has satisfied the recuirements of this Category "A" item."
The above statenents for Items 2.1.6.a and 2.1.8.c were taken directly from the Reference B.), NRC evaluation of Category "A" implementation at Pilgrim Nuclear Power Station. We do not agree that license conditions related to these items l
1 should be the vehicle of implenentation. As stated above, these programs are already in effect at Pilgrim and if placed in the License as suggested would re-quire a License Anendment with the associated increased volume and detailed paperwork every time a slight change to either program was desired. Since the Cannission is acutely aware and sensitive to existing and possible future-
- Time specified in this paragraph refers to actual analysis time for each sample.
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COOTON E01 CON COMPANY j
Mr. Thomas. A. Ippolito, Chief November 6,1980 Page 4
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Technical Specifications that may in fact be decreasing the effectiveness of those Technical Specifications concerned with matters of more imediate i
importance to' the safe operation of the facility. (Reference F), we feel that incorporating these items into the station procedures and training programs as they have been at Pilgrim Station is the appropriate method of implementation 4
for these items.
1 We trust you will find this letter satisfactory. Should you have any questions however, please do not hesitate to contact us.
i Very truly yours, 2
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i cc: Mr. J. Wetmore Office of Nuclear Reactor Regulation r
U.S. Nuclear Regualtory Conuni:sion Washington, D. C.
20555
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